There would be a difference with the struggling strangulation victim for another reason as well. In those cases, the victim was strangled to death, and there was no other factor in the death. In JBR's case, there was another cause of death; one coming so close to the strangulation that the coroner was not able to separate them from a biological aspect. IF she was strangled first, why bash her head at all? It was not apparent by looking at her. If you needed to make sure she was dead, why not just keep twisting the cord? How much longer would it have taken? There was no rush- they, after all, took their time wiping and redressing the body, looking for the blanket, unwrapping presents to find just the right pair of new panties, writing the ransom novella, wiping the flashlight, etc.